Regulatory framework aeromodelism

    Aeromodels and aeromodellers are subject to compliance with Implementing Regulation (EU) 2019/947 applicable since 31 December 2020, provided that such flights do not take place inside buildings or fully enclosed spaces.


Registration as UAS Operators

    Regardless of the different options indicated later for the practice of aeromodelling, all pilots of aeromodels must be registered as UAS operators whenever they intend to perform flights:

    • With aeromodels having a maximum take-off mass (MTOM) exceeding 250 grams or which, in the event of a collision, can transfer kinetic energy to a human greater than 80 joules (e.g.racersdrones).
    • With aeromodels that have sensors capable of capturing personal data and are not considered toys (according to Directive 2009/48/EC), such as with MTOM & 250g camera or video, except toys.
    • In the ‘specific’ category (Art. 14.5.b Reg.(EU)2019/947).

    Registration as an operator of UAS is free and is done through the electronic headquarters of AESA. To perform such registration there are two options:


    The minimum age to register as a UAS operator is 16 years. For those users with a lower age, they must operate under the cover of a registered UAS operator.

    With regard to the registration of aircraft in the application of EASA, there is an obligation to register aircraft models only when it is intended to operate in a “specific” category.


Flight with Aeromodels

    Currently, and for a transitional period until 1 January 2023, the practice of modelling in Spain can be carried out according to one of the following 4 options, provided that the conditions defined in each of them are met and is registered as UAS operator as indicated in the previous section:

    Option 1 Flights in ‘open’ category complying with the particular requirements of subcategory A3 according to Regulation (EU) 2019/947

    These flights must be carried out in areas where no non-participating person is endangered and at least 150 m horizontal distance from residential, commercial, industrial or recreational areas. In addition, the maximum flight height limitation on the ground of not more than 400 ft (120 m) must be respected.

    Aeromodels must have a maximum take-off mass of less than 25 kg and pilots have passed the training and examination corresponding to subcategory A1/A3.

    For more information on the operation requirements in subcategory A3 click here.

    Learn more about remote pilot training and examination in subcategory A1/A3 here.

    As regards the minimum age of pilots who can fly in category ‘open’ subcategory A3, this age is set at 16 years. However, there will be no minimum age as long as the remote pilot has adequate training and flies supervised by a UAS pilot aged 16 or over.

    Option 2 Flights in private geographical areas

    A UAS geographical area is defined as a part of the airspace established by the competent authority that facilitates, restricts or excludes UAS operations in order to manage risks to security, protection, privacy, protection of personal data or the environment. 

    Pursuant to Article 15 of Implementing Regulation (EU) 2019/947, the Interministerial Defence – Transport, Mobility and Urban Agenda (CIDETMA) Commission, the competent authority for the structuring of airspace, may designate geographical areas where UAS operations are exempted from one or more requirements of the ‘open’ category.

    Geographical areas of UAS have been defined to carry out aeromodelling activities in subcategory A3, with exemption from compliance with minimum age requirements and distance pilot training set out in Implementing Regulation (EU) 2019/947, in all fields of aeromodelling published in the AIP, provided that the following alternative measures are complied with:

    • Development of specific training material including the non-conflict scheme; 
    • Explanation of the internal rules of procedure;
    • Instruction by experienced pilots; 
    • Gradual initiation to the flight of new pilots and under 16 years of age; 
    • Ongoing supervision and advice by experienced pilots;
    • Ensure a kinetic energy of less than 34 KJ in operations and a risk margin on land of at least 120 m.


    Option 3 Authorisation issued by the competent authority for UAS operations under cover of a model airline club or association

    Depending on the operations to be carried out, if they cannot be framed within the open category (option 1) and no geographical area has been established (option 2), it will be necessary to issue an operational authorisation issued by EASA at the request of a club or aeromodeling association.

    In accordance with Article 16 of Implementing Regulation (EU) 2019/947, an aeromodeling club, association or federation may request AESA to issue an authorisation to carry out operations with UAS in the framework of aeromodeling clubs or associations.

    As an example, operations that would require operational authorisation would be as follows:

    • Carried out at a height exceeding 120 m;
    • Carried out on aircraft with an MTOM exceeding 25 kg;
    • Carried out with aircraft other than privately manufactured aircraft and fitted with a combustion system;
    • Involving the overflight of concentrations of persons;
    • Performed beyond the visual range of the pilot (BVLOS);

    Authorisations that AESA may issue to aeromodeling clubs or associations shall be made in accordance with the procedures, organisational structure and management system of the aeromodeling club or association, ensuring that:

    • Pilots flying within the framework of the aeromodeling club or association are aware of the limitations and conditions defined in the authorisation;
    • Pilots flying within the framework of the aeromodeling club or association are assisted in reaching the minimum competition allowing them to drive the UAS safely;
    • The aeromodeling club or association takes appropriate measures where it is aware that a pilot does not comply with the conditions and limitations defined in the authorisation;
    • The aeromodeling club or association provides AESA with the necessary documentation for monitoring and monitoring purposes.

    The authorisation issued by EASA shall specify the conditions under which flight operations with aeromodels may be carried out within the scope of the club or association, including in each case the minimum age applicable to remote pilots. Such authorisation shall be limited to the national territory.

    To apply for authorisation of UAS operations in the framework of aeromodeling clubs and associations, the interested party may address his request to the UAS Division of AESA through the procedure authorised for that purpose. A guide for submitting applications for authorisation is made available to clubs or associations at the following link:

    Guide to the presentation of operational authorisation for aeromodelling v3

    In any case, the application should be made by the representative of the aeromodeling club, association or federation by attaching the operations manual which satisfies the requirements laid down in Article 16(2)(b) of Implementing Regulation (EU) 2019/947. For the preparation of the required operations manual, it has the following guidance material with the minimum content to include:

    Guidance material on the manual of a federation, association or aeromodeling club v1


Geographical areas of UAS

    In any case, the place of flight must comply with the local limitations that may apply (geographical areas of UAS). For more information see the section “Flights with UAS/drones (zoning)


Additional information

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